The clergyman privilege applies only to confidential communications made to a clergyman in the clergyman’s professional character as a spiritual adviser or counselor and confessions or admissions made to a clergyman in the course of discipline enjoined by the clergyman’s church.
Criminal
Mullins v. State, No. 20S-CR-451, __ N.E.3d __ (Ind., Jul. 6, 2020).
Defendant’s 24½-year sentence, based on multiple controlled buys of methamphetamine over a two-week period and the resulting traffic stop, which uncovered additional contraband, was inappropriate.
Combs v. State, No. 19A-CR-1991, __ N.E.3d __ (Ind. Ct. App., Jul. 9, 2020).
An inventory search must serve a legitimate administrative purpose and not be a pretext for an investigatory warrantless search.
McCain v. State, No. 20S-CR-281, __ N.E.3d __ (Ind., June 30, 2020).
Trial court’s comments disagreeing with the jury’s verdict were insufficient to taint the sentencing decision, and the sentence was not inappropriate given the nature of the crime and defendant’s demonstrated character
Shorter v. State, No. 19A-CR-2904, __ N.E.3d __ (Ind. Ct. App., July 6, 2020).
That officers knew defendant wanted to leave town was an exigent circumstance justifying defendant’s warrantless arrest.